Lexplug logoLexplug

Sumner v. Shuman

Supreme Court of the United States
1987 U.S. LEXIS 2865, 97 L. Ed. 2d 56, 483 U.S. 66 (1987)
ELI5:

Rule of Law:

A statute that mandates the death penalty for a prison inmate convicted of murder while serving a life sentence, without allowing for the consideration of any mitigating circumstances, violates the Eighth and Fourteenth Amendments.


Facts:

  • In 1958, Raymond Wallace Shuman was convicted of first-degree murder for the shooting death of a truckdriver during a robbery.
  • For the 1958 murder, a Nevada court sentenced Shuman to life in prison without the possibility of parole.
  • In 1975, while serving his life sentence, Shuman killed a fellow inmate by burning him with a flammable liquid.
  • The incident with the fellow inmate resulted from a fight about opening a window near their cells.
  • At the time of the second murder, a Nevada statute was in effect that defined murder by a person under a sentence of life imprisonment without parole as 'capital murder.'
  • This statute mandated that every person convicted of capital murder shall be punished by death.

Procedural Posture:

  • Raymond Wallace Shuman was convicted of capital murder in a Nevada state trial court.
  • Pursuant to a state statute, the trial court mandatorily sentenced Shuman to death.
  • On direct appeal, the Nevada Supreme Court affirmed the conviction and sentence.
  • Shuman's subsequent state habeas corpus petition was denied.
  • Shuman filed a petition for a writ of habeas corpus in the U.S. District Court for the District of Nevada.
  • The District Court granted the petition in part, holding that the mandatory death sentence was unconstitutional and ordered it vacated, allowing the state to conduct lawful resentencing.
  • The State of Nevada appealed the District Court's judgment to the U.S. Court of Appeals for the Ninth Circuit.
  • The Ninth Circuit Court of Appeals affirmed the District Court's judgment.
  • The U.S. Supreme Court granted certiorari.

Locked

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does a state statute that mandates the death penalty for a prison inmate convicted of murder while serving a life sentence, without allowing for consideration of mitigating circumstances, violate the Eighth and Fourteenth Amendments?


Opinions:

Majority - Justice Blackmun

Yes. A statute mandating the death penalty for a prison inmate convicted of murder while serving a life sentence violates the Eighth and Fourteenth Amendments. The fundamental respect for humanity underlying the Eighth Amendment requires consideration of the character and record of the individual offender and the circumstances of the particular offense as a constitutionally indispensable part of the process of inflicting the penalty of death. The two elements of the Nevada statute—that the defendant was a life-term inmate and that he committed murder—do not provide an adequate basis for determining if death is the appropriate sanction, as they do not account for mitigating factors such as the defendant's personal history, prison record, level of culpability in the crime, or other circumstances like emotional disturbance. The Court rejected arguments that such a mandatory sentence is necessary for deterrence or retribution, noting that a guided-discretion statute still provides a powerful deterrent and that other sanctions exist even for life-term inmates.


Dissenting - Justice White

No. The state statute does not violate the Eighth and Fourteenth Amendments. A state legislature should be permitted to determine that for the exceedingly narrow and aggravated category of first-degree murder committed by a prisoner already serving a life sentence for a prior murder, no amount of mitigating evidence could ever outweigh the aggravating factors. An inmate who murders while serving a life sentence has no constitutional right to persuade a sentencer to impose essentially no punishment for taking another life. A mandatory death penalty in this context maintains the full deterrent effect of capital punishment, which is inevitably lessened by allowing inmates to successfully argue for a lesser sentence.



Analysis:

This decision solidifies and expands the principle of individualized sentencing in capital cases, first established in cases like Woodson v. North Carolina. By striking down a mandatory death penalty statute for even this most narrowly defined and aggravated class of offender, the Court effectively closed the door on all forms of mandatory capital punishment. The ruling establishes that there are no exceptions to the constitutional requirement that the sentencer must be allowed to consider all relevant mitigating evidence about the defendant's character and the circumstances of the crime. This precedent reinforces that the process of determining a capital sentence requires a 'reasoned moral response' to the specific individual and offense, making individualized consideration a bedrock principle of Eighth Amendment jurisprudence.

G

Gunnerbot

AI-powered case assistant

Loaded: Sumner v. Shuman (1987)

Try: "What was the holding?" or "Explain the dissent"